timely responses to communications by email and telephone timely production
of documents especially medical counsel for plaintiffs advising their
clients about early settlement and realistic expectations counsel for defendants advising their
clients to attend mediations with sufficient settlement authority expertise in a particular area
of law posturing and egotism on both sides claims for punitive damages where
none are warranted under law preparation for significant events such as examinations for discovery and motions accountability for the consequences
of steps taken or delayed unnecessary or defensive crossclaims and third party claims by defence counsel regional differences (some local bars are more collegial than others)